The first page of the proposed form has information in the loan amount, taxes, down payments and tools to compare the loan to others. The second page contains a detailed loan estimate with an estimate of what the consumer would pay at closing.

In comment letter to the bureau, NAFCU expressed concern about a confusing disclosure requirement for monthly loan payments. It makes no sense to “give a precise figure for the monthly loan payment in one section, then round the same monthly loan payment in another section. It would seem preferable to treat figures consistently throughout the disclosures," it said.

NAFCU also expressed concern about a requirement to ask borrowers early on in the process whether they plan to use an attorney because doing so would “seem to provide little value during the early stages of the lending process.”

CUNA and NAFCU both urged the bureau to take an expansive definition of what constitutes “larger participants” on rules for regulating nondepository institutions. Both said the agency should use the company’s market share as a primary basis to for determining how such firms should be regulated.

CUNA Senior Assistant General Counsel Michael Edwards said using any other approach would only result in the CFPB regulating the largest national companies rather than those who may be strong in a particular state or region. He also urged the CFPB to work with state regulators to avoid duplication.

NAFCU Regulatory Affairs Counsel Dillon Shea said the regulations should be broad enough to cover large retailers such as Home Depot and Wal-Mart that offer credit cards and other financial services.

The CFPB can’t begin regulating nondepository intuitions until it has a permanent director in place.President Obama has nominated Richard Cordray, who heads the bureau’s enforcement division, as its director. The Senate Banking Committee has scheduled a hearing on the nomination next month.